A Severance Policy for Scotland - consult.gov.scot · The Scottish Government places a high value...

A Severance Policy for Scotland

Consultation on severance arrangements across the devolved public sector

March 2017

2

About this consultation

Consultation is an essential part of the policy making process. It gives us

the opportunity to get your opinion and expertise on a proposed area of

work. You can find all Scottish Government forthcoming, open and closed

consultations online at: http://gov.scot/publications.

Each consultation details the issues under consideration, as well as a way

for you to give us your views, either online, by email or by post. After a

consultation is closed we publish all responses where we have been given

permission to do so.

Responses are analysed and used as part of the policy making process,

along with a range of other available information and evidence. Responses

to this consultation will help to inform whether reform of severance

arrangements is required in the devolved public sector in Scotland

To inform this consultation and provide a picture of exit payment activity

across the devolved public sector, Scottish Government officials sourced

data using a number of different methods. One data source utilised a

pre-consultation data gathering exercise which sought details on severance

schemes, number and cost of exits by salary band and length of service

from a range of devolved public bodies, including Health bodies,

Non-Departmental Public Bodies, Police Scotland the Scottish Fire and

Rescue Service and the Further Education (college) sector. Separately,

additional data was sourced from NHSScotland Annual Accounts and

received from Audit Scotland in respect of local authorities.

The results of the data gathering exercise forms the basis for the tables and

statistics referred to in Section 3. The response rate to the pre-consultation

data gathering was 77 per cent of those public bodies surveyed. While not

presenting a complete position, it does provide an indicative picture on

exits in the devolved public sector in Scotland.

Deadline

The consultation was published on 31 March 2017 and closes at midnight

on 23 June 2017.

http://gov.scot/publications

3

How to respond

You can respond to this consultation online, by email or by post:

Respond online

To respond online please use the Scottish Government's Consultation

Hub, Citizen Space at http://consult.scotland.gov.uk.

You can save and return to your response at any time while the

consultation is open. But please ensure your response is submitted

before the consultation closes at midnight on 23 June 2017. You will

automatically be emailed a copy of your response after you submit it.

If you choose this method you will be directed to complete the

Respondent Information Form.

The Respondent Information Form lets us know how you wish your

response to be handled and, in particular, whether you are happy for

your response to be made public.

Respond by email

You can respond by email to: [email protected].

If you respond by email, please ensure you complete the Respondent

Information Form provided at Annex A and attach it alongside your

response.

Respond by post

If you prefer you can also submit a written response in hard copy to:

Susan Gray

Financial Strategy Division

Area 3C-North

The Scottish Government

Victoria Quay

Edinburgh

EH6 6QQ

If you respond by post, please ensure you complete the Respondent

Information Form provided at Annex A and attach it alongside your

response.

http://consult.scotland.gov.uk/

mailto:[email protected]

4

Next Steps

After the consultation has closed all the responses received will be

analysed to help inform whether reform of severance arrangements is

required and if so what shape the changes may take.

Where permission has been given, we will make all responses available to

the public at https://consult.scotland.gov.uk/. The responses to the

consultation and analysis will be published during summer 2017.

Enquiries and complaints

If you have a query about the consultation process or a complaint about

how this consultation has been conducted you can send your query by

email to: [email protected] or by hard copy to the

address above.

https://consult.scotland.gov.uk/

mailto:[email protected]

5

Executive Summary

The Scottish Government seeks to ensure severance arrangements are fair

and equitable while providing value for money for the people of Scotland.

Severance continues to play an essential role in ensuring employers across

the public sector in Scotland deliver services efficiently and effectively by

enabling them to manage changes to workforces in reaction to changing

organisational circumstances - while at the same time helping leavers

bridge the gap into new employment.

Scottish Ministers want to hear your views on whether recent powers

should be used - or other reforms taken forward - to achieve better

outcomes by delivering best value to taxpayers, flexible and responsive

public services and a fair deal for public sector employees, through

changing exit payments arrangements, in particular through the

introduction of an exit payment cap, recovery of exit payments and

changing exit payment terms.

Across the devolved public sector in Scotland, over 3,000 exit payments at

a cost of £119 million were made in 2015-16. In most cases, the cost of this

exit payment is recovered from the year-on-year savings from no longer

paying salary for such posts. This consultation represents an opportunity to

provide assurance this is money well spent and assess whether reform is

required.

To do this, the Severance Policy for Scotland consultation will set out

current practice across the public sector landscape to manage and control

severance arrangements and the underpinning policy set out by the

UK Government. It will ask you to consider four policy options and whether

there is a case for change to severance arrangements in the devolved

public sector in Scotland and if so, what that change could look like.

Following your response to this consultation, Scottish Ministers will

consider all responses and decide what option to take forward; balancing

the maintenance of constructive relationships with unions and employers,

value for money for the taxpayer and the fair treatment of the public sector

workforce.

6

1 Introduction

In December 2016, as part of Scotland’s Budget for 2017-18, Scottish

Ministers announced their intention to consult on severance policy across

the devolved public sector in Scotland.

This is, in part, as a result of powers conferred on Scottish Ministers (by

way of Westminster Acts for which legislative consent motions were agreed

by the Scottish Parliament) in relation to capping and recovery of exit

payments in devolved public sector bodies and existing powers that relate

to exit payment terms. Combined, they create the opportunity to review

existing practices and consider the best approach for the devolved public

sector in the future.

The Scottish Government approach to public sector terms and conditions,

which includes severance schemes and public sector pay policy, is based on

a commitment that they are fair, affordable, offer value for money. We

remain committed to a policy of no compulsory redundancy for those

bodies which Scottish Ministers control pay and to the promotion of a

consistent approach across the public sector, effective governance and

control over severance schemes and meets the needs of employers and

employees.

The Scottish Government places a high value on the role of trade unions,

encouraging partnership working between employers and trade unions

around the delivery of flexible and responsive public services and the

support offered to those employed in public service, including in the design

and application of severance schemes.

This consultation is intended to support this overall approach, in the

interests of the sustainability of the public finances and the effectiveness of

public services.

7

2 Background

2.1 UK Government reforms and Scottish Ministers’ powers

The UK Government’s reform of public sector exit payments includes: the

ending of six-figure exit payments for public sector workers by capping the

total cost of an exit payment to £95,000; and the recovery (clawback) of

public sector exit payments when a high earner (defined as someone who

was on a salary of £80,000 or more) returns to work in the public sector

within 12 months, based on the premise that it is right to examine whether

there is sufficient assurance to the taxpayer that these exit pay

arrangements are fair and represent value for money.

The UK Government is likely to deliver some of these reforms through

regulations under the Small Business, Enterprise and Employment Act 2015

(‚the 2015 Act‛). The Scottish Ministers have powers under the 2015 Act

which enable them to make Regulations on whether to cap and/or recover

exit payments in the devolved sector. These add to existing controls over

exit payment terms for that sector. The Scottish Government is under no

obligation to use the 2015 Act powers.

Furthermore, the UK Government initiated a cross public sector reform of

exit payment (severance) terms with the aim of reducing costs of

redundancy payments and ensuring greater consistency between

workforces. This UK Government initiative does not extend to the devolved

public sector.

2.2 Changes to Civil Service Compensation Scheme

Changes to the exit payment terms of the Civil Service Compensation

Scheme have already been made. The exit cap will come into force for most

staff covered by the Civil Service Compensation Scheme when relevant

Regulations are made by a UK Minister. As the terms of the Civil Service

Compensation Scheme are reserved to the UK Government, changes to it

apply to around 19,200 civil servants working for the Scottish Government

and to those working for devolved Scottish bodies who elected to be part of

the Civil Service Compensation Scheme.

2.3 Fair Work

The Scottish Government is committed to ensuring severance packages are

fair and equitable while also providing value for money for the people of

Scotland. Exit payments associated with the loss of employment are an

important part of an employer’s ability to flex their organisational structure

8

to react to new circumstances and they also provide important support for

employees as they find new employment. All such compensation

arrangements should be proportionate and offer value for money.

Public sector workers play a crucial role in delivering services essential for

the country and supporting our economy. The Scottish Government

supports the independent Fair Work Convention’s vision to embed a culture

of fair work throughout all workplaces in Scotland and is committed to

being an exemplar of fair work itself. The Fair Work Convention’s

Framework recognises fair work as that which offers effective voice,

opportunity, security, fulfilment and respect. For employees, fair work

brings increased financial security, better physical health and greater

psychological wellbeing. Employers will, in turn, see less absence, greater

productivity and enjoy a good reputation as a fair employer.

2.4 Exit payment value for money and affordability

As part of the Scottish Ministers’ commitment to no compulsory

redundancy, employers make every effort to find alternative employment

for employees as part of re-shaping workforces to support service delivery

or underpin public service reforms. Where this is not possible they offer

voluntary exit schemes.

Exit payments should represent value for money to the tax payer, be

affordable to the public purse and facilitate the sustainable delivery of

public services through an engaged, committed and flexible workforce. Exit

payments help unlock substantial reductions in staff costs in the medium to

long term which are needed to meet the continuing challenge of budget

pressures across the public sector. In most cases, the cost of this exit

payment is recovered from the year-on-year savings from no longer paying

salary for such posts.

In 2013, the Audit Scotland report Managing Early Departures from the

Scottish Public Sector acknowledged that

‚voluntary exit schemes can provide significant savings and that public

bodies generally provide good practices‛.

Given the scale of costs associated with the exit payments it is vital that

they continue to offer best value. The Audit Scotland report also

commented

‚there is evidence to show that Scotland’s public sector generally follows

the principles of good practice. Many have up-to-date policies on their

early departure schemes. Wider workforce strategies are used by

organisations to help decide where they need to reduce staff numbers or

9

which grades they need to reduce. Most use some form of business case

to help decide if early departure will lead to savings.‛ (‘Key Messages’,

page 4)

Ensuring that exit packages offer flexibility to employers, support to

employees and value for money to the taxpayer, are key drivers of any

decision around the implementation of an exit cap or recovery

arrangements.

2.5 Devolved powers over exit payment caps, recovery and reform of

payment terms

Under these powers, Scottish Ministers can decide whether to adopt an exit

payment cap and/or recovery measures similar to those being implemented

by the UK Government or set a different level of cap and/or salary ceiling

in relation to recovery provisions. They could also specify the types of

payments to be included in that cap and/or recovery provisions.

In addition, the Scottish Ministers could choose to delegate powers to a

body in respect of exit payments made by the body or to exempt particular

bodies or sectors from the cap or recovery measures.

The table below provides the underpinning policy approach being taken by

the UK Government in applying exit payment cap (to the total cost of exit

payments to the employer) and recovery provisions as well as outlining

their approach to reforming exit payment terms.

UK GOVERNMENT POLICY POSITION

Exit

Payment

Cap

Cap the total cost of exit payments available to individuals leaving

employment to £95,000

Apply the cap to all types of arrangements for determining exit

payments

To cover payments made in relation to leaving employment

including:

o Voluntary and compulsory exits

o Other voluntary exits with compensation packages

o Ex gratia payments and special severance payments

o Other benefits granted as part of exit process that are not

payments in relation to employment

o Employer costs of providing early unreduced access to pensions

(or any form of pension ‘top-up’)

o Payments or compensation in lieu of notice and cashing up of

outstanding entitlements

Where a number of payments are made these will be aggregated

together to be measured against the cap

10

Payments out of scope

Compensation payments in respect of death or injury attributable to

the employment, serious ill health and retirement and certain fitness

requirements

Payments made in compliance with an order of court or tribunal

Relaxation process

The relaxation of the cap would require consent from relevant

Minister

Full council to take decisions on waiver in cases involving local

authorities

Compliance and transparency

Requires bodies to maintain records and publish annual details of all

exit payments relaxed within a financial year


Recovery of

Exit

Payments

Exit payments are recovered on return to any part of the public

sector, including for members of the Civil Service Compensation

Scheme in Scotland and reserved public sector in Scotland

The minimum salary at which recovery of exit provisions apply is

£80,000 per annum

Exit payments recovery will be tapered from date of exit up to

12 months. None after 12 months

Payments included for loss of employment, including discretionary

payments and to buy-out actuarial reductions to pensions and

severance payments

Excluded payments

o Potential if not actual monetary value

o Payments and compensation in lieu of notice

o Payments equal to minimum statutory redundancy

o Payments made in respect of incapacity or death as a result of

accident, injury or illness

o Payments made in respect of leave not taken

o Payments made in compliance with an order of court or tribunal

Mechanism for enforcement are that former employer is entitled to

take an individual to court to reclaim money.

Transparency – bodies that grant a waiver disclose this as part of

annual reports and accounts


Exit

Payment

Terms

A maximum tariff for calculating exit payments of three weeks’ pay

per year of service. Employers could apply tariff rates below these

limits

A ceiling of 15 months on the maximum number of months’ salary

that can be paid

A maximum salary on which an exit payment can be based, as a

starting point of the NHS scheme salary limit of £80,000

A taper on the amount of lump sum compensation an individual is

entitled to receive as they get closer to pension age

Act to limit or end employer-funded early access to pension within

exit packages. Proposals could be:

o Cap the amount of employer funded pension ‘top-up’ payments

to no more than the amount of the redundancy lump sum to

which that individual would otherwise be entitled

11

o To remove the ability of employers to make ‘top-up’ payments

altogether

Increase the minimum age at which an employee is able to receive

an employer funded pension ‘top-up’, so that this minimum age is

closer to or linked to Normal Pension Age

Payments in Scope

General limits would be imposed on most employer-funded

payments made in relation to leaving employment, including

compensation packages for exits whether in impending or declared

redundancy situations or in other situations where individuals leave

the public sector employment with an employer-funded exit package

Any increase in the minimum age at which an employee might be

able to receive a pension ‘top-up’ on voluntary or compulsory exit

may apply to payments under the major public sector compensation

or schemes

These reforms will not affect any payments made in relation to

death or injury attributable to duty or ill-health retirement.

2.6 Definition of exit payments related to severance

Exit payment is the term used within this document to refer to any financial

or non-financial transfer to an employee or employer which does not

represent remuneration for normal on-going activities that are part of their

employment. This excludes, for example: wages, salary, allowances and

regular non-financial benefit packages such as a company car.

Exit payments may come in a number of different forms including (this list

is not exhaustive):

Cash lump sum– such as a redundancy payment, normally calculated on

the basis of salary at the point of exiting the organisation and length of

service

Early access to unreduced pension– some employers offer the option for

employees who have reached the relevant age to take early retirement

on an ‘unreduced’ pension, in place of, or in addition to, a cash lump sum

compensation payment. In these instances, employers bear the cost of

‘buying out’ the actuarial reduction that would normally apply to a

pension that was taken early

Non-financial and other benefits– in a smaller number of instances

employers may offer other benefits such as additional paid annual leave

at the end of an individual’s employment

Payments in lieu of notice – employers may also offer a cash payment

equivalent to the sum that would otherwise have been earned had a

notice period been worked by the employee

12

2.7 Aim of the consultation - policy options

The Scottish Government recognises the role of severance arrangements in

enabling organisations to re-shape workforces and ensuring continued

delivery of flexible and responsive public services. At a time when budgets

are under pressure and as part of their continued commitment to fair work,

Scottish Ministers are considering whether there is a case for reform of

severance arrangements across the devolved public sector.

The Scottish Government is not consulting on the basis of a preferred way

forward, but instead wishes to ensure that decisions about a Scottish

Approach to future policy are informed by as many voices as possible. This

consultation seeks to explore four broad policy options:

Option 1 Status quo

Current compensation arrangements meet best value and deliver against

fair work principles, accepting a level of continuing variance of practice

across workforces that reflects the devolution of responsibilities to

individual sectors and employers; or

Option 2 Non-legislative change

Consider reforms to current devolved compensation arrangements that

would improve value for money and the delivery of fair work principles but

which do not require the use of powers conferred on Scottish Ministers by

the 2015 Act; or

Option 3 Replicating UK arrangements

Agree to make reforms along the lines of the UK Government proposals: to

implement a £95,000 exit payment cap; recovery of exit payments where

someone earned more than the £80,000 threshold and returned to work in

the public sector within 12 months; and make changes to exit payment

terms; or

Option 4 A hybrid approach

Agree to reform using the powers conferred on Scottish Ministers and

implement a hybrid of legislative and non-legislative change which could,

for example, strengthen existing severance arrangements and/or introduce

some form of different cap and/or recovery arrangements.

13

In taking forward these four options, consideration will be given to the

impact that changes to compensation arrangements can make on the

following factors:

Industrial relations and Fair Work principles

On delivering flexible and responsive public services

A desire to ensure that severance payments are not excessive and offer

value for money

Ability to ensure there is greater consistency of application across

sectors, including between the reformed Civil Service Compensation

Scheme and devolved schemes, where that is seen to be valuable

Ability of employers to continue to re-shape organisations and deliver

services

The risks and opportunities presented by taking different approaches

where there is a UK-wide labour market

Your response to this consultation will help Scottish Ministers to consider

whether reform of severance arrangements across the devolved public

sector is required and, if so, which policy option should be developed by

Scottish Ministers.

We are particularly interested in hearing from:

Public sector employers and their representative associations

Employees and their representative bodies

Members of the academic community with expertise in this area

Pay, pension, remuneration and HR professionals in both private, public

sector and third sector.

Following any decision to make changes to current severance

arrangements, we will seek further engagement with workforces across the

devolved public sector on the implementation of these changes.

2.8 Which bodies are in scope

All devolved public sector bodies (employees and office holders) are in

scope. There is a list of entities classified as within the central and local

government and non-financial public corporation sectors by the Office for

National Statistics for National Account purposes, on which the

UK Government base their scope for capping and recovery (subject to

exemptions).

14

The list includes the main bodies listed below;

Non-Departmental Public Bodies (who are not part of civil service

pension arrangements)

22 NHSScotland bodies

26 Further Education institutions (colleges)

32 local authorities

Police Scotland and the Scottish Police Authority

Scottish Fire and Rescue Service

6 public corporations

Furthermore, a number of new bodies will be established after 1 April 2017

and any provisions may also cover them.

The list of bodies can be found on the Office for National Statistics website

at:

www.ons.gov.uk/economy/nationalaccounts/uksectoraccounts/datasets/pu

blicsectorclassificationguide.

Question 1

What types of bodies or bodies themselves do you think SHOULD be

covered?

Please give reasons for your response.

Question 2

What types of bodies or bodies themselves do you think SHOULD NOT

be covered?


2.9 Bodies covered by reserved arrangements

Devolved public sector bodies employing civil servants or those who do not

employ civil servants but whose staff are part of the civil service pension

arrangements will be subject to Civil Service Compensation Scheme rules

set by the UK Government. Such bodies would not be affected directly by

the findings of this consultation and any future policy decisions. However,

we recognise that these bodies will have an interest in the consultation and

severance and would welcome their contribution.

http://www.ons.gov.uk/economy/nationalaccounts/uksectoraccounts/datasets/publicsectorclassificationguide


15

3 Severance arrangements across the devolved

public sector in Scotland

In assessing the case for reform, understanding the effectiveness of the

current landscape can provide clear indicators on whether or not change is

required and, if so, where any change is necessary.

This section of the consultation document sets out the current severance

landscape, across the devolved public sector in Scotland. This includes what

controls are in place for severance arrangements, the terms of severance

schemes, costs and savings of exits and outlines the length of service and

pay bands of those who have exited.

Control of severance schemes in the devolved public sector

3.1 The Scottish Public Finance Manual

Severance payments in bodies accountable to Scottish Ministers must

comply with requirements in Scottish Public Finance Manual. Scottish

Ministers, sign-off exit payments in such bodies. The Scottish Public Finance

Manual emphasises the need for economy, efficiency and effectiveness, and

promotes high standards of propriety.

In considering terms for settlement agreements, severance, early

retirement or redundancy packages - whether compulsory or voluntary -

public bodies to which the Scottish Public Finance Manual applies should

ensure that issues of legal and regulatory compliance, propriety and value

for money are fully taken into account, alongside employee relations issues:

In order to secure voluntary resignation of an employee out with an

existing or approved scheme, any voluntary exit or other severance

(including settlements) a business cases needs to be submitted and

approved by the Scottish Government.

In arriving at a decision on approval the Scottish Government will

consider comparability to Scottish Government equivalent schemes and

to the overarching Civil Service Compensation Scheme rules currently in

force, along with an assessment of the regularity, propriety and value

for money offered by the proposals.

The benefit structure and terms of compensation schemes for severance,

early retirement or redundancy provided by Scottish Government

sponsored bodies - or separately by any constituent parts of the Scottish

Administration - should be broadly similar to the arrangements in place

within the core Scottish Government and set out in the Civil Service

Compensation Scheme - as amended or replaced periodically.

16

The public body must obtain prior approval from the Scottish

Government for a new scheme or changes to a previously approved

scheme.

Comply with specific requirement to disclose remuneration relating to

exit costs in annual accounts.

The Scottish Government made improvements to the regulation of

severance payments in the public sector following the Audit Scotland report

in May 2013. This included bringing more public bodies within the scope of

the Scottish Public Finance Manual.

For those organisations that are not subject to the Scottish Public Finance

Manual, such as local authorities, the Scottish Government expects them to

meet their duties to deliver best value while also ensuring fairness to their

staff.

In local authorities, decisions on exit payments are reported at a full council

level annually, with reports providing information on the costs and savings

of all exit payments. The Local Government in Scotland Financial Overview

Report 2015-16 by Audit Scotland acknowledges the role exit packages

play in managing workforces and stated:

‚Councils’ decisions on reducing their workforce numbers through exit

packages are supported by business cases which set out the associated

costs and potential savings. Councils will typically expect to recoup the

costs and start making savings within a few years.‛ (page 18)

3.2 Existing severance schemes by workforce

This section of the consultation sets out key details of the severance

schemes by workforce. This was provided using data gathered from across

the devolved public sector prior to this consultation.

NHSScotland - covered by the Agenda for Change terms and conditions. All

severance schemes are on a voluntary basis and based on an individual’s

contractual terms and conditions.

Number of weeks’ pay: One month’s pay for each year of NHS service, up

to a maximum of 24 years (giving a maximum of 104 weeks).

Voluntary early retirement (access to pension): At the employer’s

discretion, employees may also be offered early retirement in the

interests of the efficiency of the service. In these situations, the

employer covers the costs of providing full pension benefits early.

Payback period: A key affordability indicator (how long it takes to re

coup the costs of the exit) the majority of NHSScotland bodies use a

17

payback period of between one and two years, with some having either

a case by case payback period or no formal payback period in place.

Police - both Police Scotland and the Scottish Police Authority are covered

by the same severance arrangements. Severance schemes only apply to

police staff and not police officers.

Number of weeks’ pay: For voluntary redundancy: A maximum of five

weeks’ per year, up to a limit of 66 weeks and a maximum lump sum of

£10,000.

Voluntary early retirement (access to pension): After the age of 50,

employees receive an employer ‘top-up’ of up to four compensatory

added years to pension as well as a service based lump sum up to a

maximum of 30 weeks.

Payback period: Both Police Scotland and the Scottish Police Authority

use a payback period of three years.

Local Government and Teachers - covered by similar severance policy,

although some differences exist in their pension arrangements. A recent

survey undertaken by Fife Council into local government severance

schemes indicated some variance in practice in the terms of the scheme.

Number of weeks’ redundancy pay: 76 per cent of respondents (to the

data gathering exercise) used between 30 and 66 weeks’ pay to calculate

an exit payment with 24 per cent above this threshold. The highest

number of weeks’ pay was 82.

Voluntary early retirement (access to pension): 75 per cent of

respondents give employees exiting in such circumstances

Compensatory Added Years (this is a discretionary element of exit

payments i.e. ‘top-up’). Of the councils offering added years: 11 gave up

to five added years, with seven councils offering six added years.

Payback period (value for money test): Used by all local authorities. The

majority of which (75 per cent) used a payback period of between two

and three years. Five councils have a payback period of up to five years,

or on a case by case basis.

Uptake of voluntary early severance / voluntary early retirement can be a

concern for employers seeking to re-shape their workforce. Although

employers’ views on uptake were generally positive, with over 80 per cent

saying they felt they could ‚attract sufficient volunteers to meet required

workforce reductions at present and in future, based on projected needs‛.

(Fife Council survey results)

18

Some councils expressed concern for the future and the need to balance the

ongoing cost of schemes against the need for them to remain sufficiently

attractive to manage workforce reduction consensually. (Fife Council survey

results)

Further Education sector - all severance schemes are overseen by the

Scottish Funding Council.

Number of weeks’ pay: There is a variation between 30 weeks’ pay

(statutory) with a maximum of 60 weeks’ pay recorded.

Voluntary early retirement (access to pensions): Practice varied across

respondents with the majority saying that they did not offer this. Those

who did offer early access to unreduced pensions did so, where pension

rules allowed.

Payback period: Almost all colleges who responded used an payback

period of between one and two years. Very few colleges have a payback

period of either 18 months or a maximum of three years.

Non-Departmental Public Bodies, public corporations and the Scottish Fire

and Rescue Service - there are variety of arrangements in place. All

severance schemes are on a voluntary basis and agreed by the Scottish

Government.

Number of weeks’ pay: Across public bodies who responded there is a

variation between 30 weeks’ pay (statutory) with a maximum of

104 weeks’ pay.

Voluntary early retirement (access to pensions): Practice varied across

bodies with the majority of respondents saying that they did offer this,

with similar provisions as in local authorities.

Payback period: Almost all bodies who responded used a payback period

of between one and two years. Very few bodies had a payback period of

either 18 months or a maximum of three years.

In some circumstances, there was no qualifying period for voluntary

severance set out and in all circumstances there are no recovery of exit

payment arrangements in place.

Question 3

Given the variation exit in schemes across the public sector, is there

benefit in seeking to make this more consistent to deliver best value and

Fair Work outcomes? Yes / No


19

3.3 Exit payment costs

To inform the consultation, Scottish Government officials gathered data on

exit payment activity across the devolved public sector, using a number of

different methods. One data source utilised a pre-consultation data

gathering exercise (response rate of 77 per cent)which sought details on

severance schemes, number and value of exits by salary band and length of

service from a range of devolved public bodies, including Health bodies,

Non-Departmental Public Bodies, Police Scotland the Scottish Fire and

Rescue Service and the Further Education (college) sector. Separately,

additional data was sourced from NHSScotland Annual Accounts and

received from Audit Scotland in respect of local authorities. This provides

an indicative picture of exits in the devolved public sector.

From the results of the data gathering exercise, between 2014-15 and

2016-17, the indicative cost of exits across the devolved public sector

showed over 1,000 voluntary early severance / voluntary early retirement

cases reducing to 264, with related costs coming down from £46 million to

£11 million.

From Table 1, in 2015-16, only 17 out of 560 exits (around three per cent)

cost employers over £100,000.

Table 1 Number of exits by cost band 2014-17 (excluding local

government) Exit cost by

band

2014-15 2015-16 2016-17 Total exits by

cost band

< £10,000 119 95 36 250

£10,001 -

£49,999

727 348 165 1,240

£50,000 -

£99,999

143 100 43 286

>£100,000 76 17 20 113

Total 1065 560 264 1,889

Source: Scottish Government data gathering exercise and NHSScotland Annual Accounts

Local Government information sourced did not break down exits using the exit cost band

summarised above and therefore were excluded from this analysis

20

Table 2 Number and cost of exits by sector 2015-16 Devolved public

sector body

Number of exits Total cost

£

Average cost

£

Police 111 6,244,074 56,253

Further Education

colleges

171 4,979,913 29,122

NHSScotland 159 6,140,000 38,616

Public bodies (NDPBs, public

corporations, SFRS)

119 4,686,555 39,383

Local government 2,660 97,142,387 36,520

Total 3,220 119,192,929 37,016

Source: Audit Scotland, NHSScotland and Scottish Government data gathering exercise

Table 2 above shows the average exit payments by sector with an overall

average exit cost of £37,016.

Furthermore, when adding local government exit payment data we can see

total costs of exits rise to £119 million. It is important to note that local

government exit costs are proportionate to the volume of exits that occur

in that sector.

3.4 Salary and length of service indicators

An issue which could be raised in relation to an exit payment cap is

whether longer serving, mid- to low-income employees could be impacted

unfairly by the introduction of any cap. For instance, if the calculation of

the exit payment for a low-income, long-serving employee breached a cap

on exit payments.

An examination of the distribution of exit payments across the public sector

is provided below. This gives an indication of the proportion of longer

serving employees more likely to exit and be impacted by a cap if it were

to be introduced.

Table 3 Number of exits by length of service 2015-16

(excluding local government) Length of

service

at exit

10 years

or less

11 to 20

years

21 to 30

years

31 to 40

years

More

than 40

years Total

Police 45 36 24 6 0 111

Further Education

colleges 62 61 38 10 0 171

NHSScotland 16 44 29 18 5 112


corporations, SFRS) 36 44 27 5 7 119

Total 159 185 118 39 12 513

Source: Scottish Government data gathering exercise only

21

The data from Table 3, suggests fewer than ten per cent of all exits

(excluding local government) occur where employees have more than 30

years’ service.

Table 4 Number of exits by salary at exit 2015-16

(excluding local government) Salary band

(£)

0 to

22,000

22,000

to

43,429

43,430

to

69,999

70,000

to

99,999

100,000

to

149,999

150,000

to

199,999

More

than

200,000

Total

Police 49 55 7 0 0 0 0 -

Further

Education

colleges

53 98 19 * 0 0 0 -

NHSScotland 13 52 33 8 5 * 0 -


corporations,

SFRS)

38 51 24 * * 0 0 -

Total 153 256 83 12 * * 0 513

Source: Scottish Government data gathering exercise only

Note: Counts of less than five have been suppressed and shown as * to prevent the

possible disclosure of information about individuals. Secondary data suppression has also

been necessary to prevent the calculation of the suppressed values by differencing (also

shown as *)

The data in Table 4 suggests less than three per cent of exits exceeded the

£80,000 threshold beyond which recovery arrangements might begin.

Equally, this data suggests the overall picture in the devolved public sector

in Scotland is one where there are fewer exits in long serving or high

earning employees.

3.5 Severance payments associated with pension

Individuals in the public sector who have reached the required age may be

offered, or in certain circumstances have a contractual entitlement to, early

retirement on an ‘unreduced pension’ or be provided additional pension.

Employers making this offer as part of early retirement may make a

contribution (‘top-up’) to an individual’s pension that ‘buys out’ some or all

of the reduction in pension benefits.

Pension costs related to early exits could, therefore, be included which

would mean more members of the workforce would be caught by a cap.

3.6 Existing recovery arrangements

Currently some public sector bodies can choose to include recovery

measures (including limitations on return to work) in the design of their

22

severance schemes. For example, NHSScotland has recovery arrangements,

whereby if an individual secured employment elsewhere within

NHSScotland, within four weeks of receiving a payment the previous

employer would seek recovery.

While some public sector bodies do not re-engage the services of former

employees, this is only within their own organisation. It is therefore

difficult to assess the number of instances of re-engaging former employees

shortly after receiving an exit payment across the sector as a whole.

There is not a requirement for recovery measures to be applied

consistently across the devolved public sector in Scotland.

23

4 Severance policy for the devolved public

sector

Scottish Ministers are seeking your views on whether better outcomes can

be achieved for taxpayers, public sector employers and employees, by

introducing a cap on exit payments, recovering exit payments for high

earners and changing the way in which exit payments are calculated.

This section will go through each element of the UK Government’s

underpinning policy and offer you the chance to have your say.

Exit payment cap

4.1 Level of exit payment cap

An exit payment cap is a limit on the total cost of exit payments available

to an individual leaving employment to a set amount. The UK Government

is proposing a limit of £95,000.

Scottish Ministers can set the level of the exit payment cap and determine

which payments would be included in that cap, as well as provide for

relaxations, namely, circumstances where the cap can be waived.

Scottish Ministers are seeking your views on whether there would be a

policy benefit in setting a standardised cap on exit payments and, if so,

what level of cap would be appropriate, balancing best value with

re-shaping of services and flexibility to manage workforces. An exit cap

would apply as a consequence of leaving employment to all existing and

future employees of a devolved public body.

Question 4

Do you think it is necessary to set an exit payment cap for the devolved

public sector? Yes / No


If yes, do you think it should be set at the same level as per UK

Government policy (at £95,000)? Yes / No


If no, what level would be appropriate?


24

4.2 Severance arrangements covered by a cap

The UK Government’s proposals for an exit cap applies to all arrangements

which determine an exit payment. These are:

voluntary early severance / redundancy

voluntary early retirement

compulsory redundancy

contractual arrangements and collective agreements

Question 5

Which of the following exit payment arrangements (included in the

UK Government’s exit payment cap proposals) should Scottish Ministers

include in the event that a cap was to be introduced in Scotland for the

devolved public sector? Please select all you think should be included.

Voluntary early severance / redundancy

Voluntary early retirement

Compulsory redundancy

Contractual arrangements

Collective agreements


Question 6

Are there any other exit payments situations where you think a cap

should apply?


4.3 Payments included in a cap

The Scottish Government is considering carefully whether pension ‘top-up’

should be included in any future cap. Any cap which included this type of

payment could potentially make exit payments less attractive to employees

and tie employers’ hands further in their ability to re-shape workforces.

Exit payments included in the UK Government’s exit payment cap are:

Voluntary and compulsory exits

Other voluntary exits with compensation packages

Ex gratia payments and special severance payments (settlement

agreements)

Other benefits granted as part of exit process that are not payments in

relation to employment

Employer costs of providing early unreduced access to pensions

25

Any form of pension ‘top-up’

Payments or compensation in lieu of notice and cashing up of


Question 7

Which of the following exit payments (included in the UK Government’s

exit payment cap proposals) should Scottish Ministers include if a cap

were to be introduced for the devolved public sector? Please select all

you think should be included.

Voluntary and compulsory exits

Other voluntary exits with compensation packages

Ex gratia payments and special severance payments (settlement

agreements)

Other benefits granted as part of exit process that are not payments

in relation to employment

Employer costs of providing early unreduced access to pensions

Any form of pension ‘top-up’

Payments or compensation in lieu of notice and cashing up of


Other (please specify)


4.4 Payments excluded from an exit payment cap

Under the UK Government proposals, compensation payments in respect of

death or injury attributable to employment, serious ill health and ill health

retirement would be excluded, as would payments made following litigation

for breach of contract or unfair dismissal.

Question 8

Which of the following payments should Scottish Minsters exclude, if a

cap were to be introduced in the devolved public sector? Please select

all that apply.

Death or injury attributable to employment

Serious ill health and retirement and certain fitness requirements

Litigation for breach of contract for unfair dismissal

Compliance with an order of court or tribunal

Other (please specify below)


26

Exit payment recovery

4.5 Recovery of exit payments

Scottish Ministers are seeking your views on recovery arrangements, based

on fairness and value for money, whereby former employers can recover

exit payments made to employees who are subsequently re-engaged in

another public sector body within 12 months of leaving.

UK Government proposals for the recovery of exit payments (clawback)

requires higher-earning public sector employees or office holders to re-pay

exit payments on a tapered bases (for example: if nine months between

posts, only 75 per cent of monies are recovered should they return to any

part of the public sector). High earners are defined as those who earned

over £80,000. This is not applied pro rata for part-time employees.

Question 9

Should Scottish Ministers introduce a threshold for recovery

arrangements for high-earners in the devolved public sector? Yes / No

If yes, at what threshold should recovery arrangements be set?

At £80,000

Lower than £80,000

Higher than £80,000


Question 10

Over what time period should recovery arrangements apply?

At 12 months

Earlier than 12 months

Beyond 12 months


4.6 Payments to be included

Scottish Ministers could also determine what types of payments are

included. Recovery payments included as part of the UK proposal include:

those for loss of employment, including discretionary payments

to buy-out actuarial reductions to pensions and

severance payments

27

Question 11

Which of the following payments should Scottish Ministers include in the

exit payment recovery arrangements, if introduced for the devolved

public sector? Please select all those you think should be included.

Those for loss of employment, including discretionary payments

To buy-out actuarial reductions to pensions

Severance payments


4.7 Enforcement mechanisms

The UK Government proposals are that a former employer is entitled to

take an individual to court to reclaim money. The new employer will be

asked to consider dismissal if repayment arrangements are not made within

three months of starting employment.

Question 12

Do you think that enforcement mechanisms should be introduced for the

devolved public sector? Yes / No


4.8 Relaxation process

Under the terms of the UK Government’s proposals, in exceptional

circumstances and in individual cases where an exit payment exceeds the

cap, the default position would be that any relaxation of the cap would

require the consent of Ministers. For devolved public bodies on the same

basis, Scottish Ministers would approve the relaxation of the cap in

individual cases. The same provisions would apply in respect of recovery.

The UK Government policy proposes that the full council take the decision

on whether to grant a relaxation of cap in cases involving local government.

Question 13

If in the event of an exit payment cap and recovery should Scottish

Ministers have: Please select all those you think should be included.

The power to waive in exceptional circumstances

Delegate the power to waive

Delegation within a certain threshold


4.9 Accountability and transparency

To ensure transparency and accountability of severance schemes and

re-engagement levels across the public sector, the UK Government’s policy

28

proposals suggest reporting of exit payments and recovery of exit

payments in the annual accounts in each organisation.

Current practice in Scotland indicates that exit payments costs and savings

are reported annually by local authorities as a result of the 2003 ‚Bye now,

pay later?‛ Audit Scotland recommendation. Furthermore, local government

exit payment costs are reported by Audit Scotland every year in Local

Government in Scotland Financial Overview Report 2015-16.

Settlement agreements (defined as payments made to the employee outside

the employer’s basic statutory or contractual entitlement, on unplanned

termination of employment) for those public bodies under the auspices of

Scottish Ministers are scrutinised and reported in the Scottish Government’s

annual report to the Scottish Parliament. This demonstrates Scottish

Ministers’ commitment to operating openly and transparently, encouraging

appropriate scrutiny of public sector operations.

All bodies across the devolved public sector are required to report exit

payment activity in their annual accounts.

Question 14

Are there other forms of reporting you think would be helpful, across

the devolved public sector in Scotland? Yes / No


Exit payment terms

4.10 Changing exit payment terms

Scottish Ministers continue to work with devolved public bodies to consider

how severance arrangements can best support maintaining high quality

public services while addressing the challenges presented by current

constraints on overall public expenditure. This context makes it essential

that severance arrangements deliver value for money.

Scottish Ministers are seeking your views on the potential benefits of

changes to exit payment terms to the devolved public sector in Scotland.

4.11 Changes to the exit payment tariff

An exit payment tariff is the method used to calculate an exit payment

usually based on length of service and salary. Scottish Ministers can change

the maximum tariff similar to that of the UK Government proposals: to

three weeks’ pay per year of service; cap the maximum salary on which the

severance payment is based to £80,000; and to cap the number of months’

29

salary that can be used when calculating exit payments to 15 months.

Scottish Ministers could choose to set a different tariff.

Question 15

Do you think there would be value in changing exit payment tariff terms

along the lines of the UK Government’s proposals: Please select all those

you think should be included.

Three weeks’ pay per year of service

Maximum level of salary on which the payment is based to £80,000

A ceiling of 15 months on the maximum number of months’ salary

that can be used

Other alternative approaches (please specify)


4.12 Payback period

Exit payment terms could be more affordable and benefit from being

consistent across the wider public sector landscape. Payback period (how

long it takes to re-coup the costs of exits) is often used as an indicator of

best value in exit payments.

Severance arrangements in devolved public sector bodies subject to the

Scottish Public Finance Manual have to be broadly comparable with Civil

Service Compensation Scheme terms which are currently 18 months.

However, across the devolved public sector there is a broad range of

payback periods in use. These range from 18 months to five years. Not all

devolved public sector bodies are subject to the Scottish Public Finance

Manual, for example, local government.

Question 16

What would be an appropriate payback period for exit payments, that

balances affordability with operational effectiveness?


4.13 Pension ‘top-up’ payments

Some employers offer pension ‘top-up’ payments as part of severance

arrangements. The UK Government policy proposals suggest that the cost of

employer-funded pension ‘top-up’ payments can be minimised, for example,

by limiting the amount of employer funded ‘top-up’ payments for early

retirement, or removing access to early retirements, but could be limited

further by applying one or more of a range of restrictions:

Cap the amount of employer funded pension ‘top-up’ payments to no

more than the amount of the redundancy lump sum to which that

individual would otherwise be entitled

30

To remove the ability of employers to make ‘top-up’ payments

altogether

Increase the minimum age at which an employee is able to receive an

employer funded pension ‘top-up’, so that this minimum age is closer to

or linked to Normal Pension Age

‘Top-up’ payments for ill-health, death in service and physical fitness could

be out of scope.

Question 17

Should Scottish Ministers apply any of the following restrictions, for

devolved public sector employers?

Cap the amount of employer funded pension ‘top-up’ payments to no

more than the amount of the redundancy lump sum to which that

individual would otherwise be entitled

Remove the ability of employers to make ‘top-up’ payments

altogether

Increase the minimum age at which an employee is able to receive an

employer funded pension ‘top-up’, so that this minimum age is closer

to or linked to Normal Pension Age



If none of the above, please give reasons for your response.

31

5 Impact analysis

5.1 Economic and fiscal

Between 2010-11 and 2019-20, the Scottish fiscal revenue budget (which

funds discretionary expenditure on public goods and services in Scotland)

will fall by around nine per cent in real terms. As the public sector paybill

represents a large proportion of devolved public expenditure, action to

make savings in paybill costs are an important part of the response that all

public bodies have been and will continue to make in the challenging

financial context.

Question 18

You are invited to provide evidence of where an exit cap or other

changes to exit payment terms would further support your

organisation’s ability to manage paybill costs?

Question 19

What do you think are the positive and negative economic and fiscal

impacts of an exit cap, changes to exit payment terms and recovery

arrangements?

What evidence do you have?

5.2 Social Impact

Scottish Ministers recognise that Scotland’s geography means it has a

dispersed workforce in rural and island areas. In such areas employers can

have more limited recruitment options. Employers may have no option but

to consider former public sector employees when filling vacancies and such

employees often have valuable skills and experience to offer. However, the

recruitment of former public sector employees could be impacted if

mandatory recovery of exit payments within 12 months of leaving means

that such employment opportunities become less attractive.

Furthermore, due to the size and nature of Scotland’s public sector, close

relationships exist between certain aspects of the public sector, for

example, between NHS and local government, which mean there is a degree

of churn across these areas of the public sector. The impact of new

provisions on recovery could slow down or hinder this type of workforce

movement.

Question 20

What do you think are the positive and negative social impacts of an exit

cap, changes to exit payment terms and recovery arrangements?


32

5.3 Environmental and regulatory impact

The Scottish Government considers there to be no direct environmental or

regulatory impact.

Question 21

What do you think are the positive and negative environmental and / or

regulatory impacts of an exit cap, changes to exit payment terms and

recovery arrangements?


5.4 Financial impact

To enable employers to re-shape services in light of budget challenges, exit

packages are one way of achieving this. Ensuring that exit packages offer

flexibility to employers, support to employees and value for money to the

taxpayer, are key drivers of any decision around the implementation of an

exit cap or recovery arrangements.

Question 22

What do you think are the positive and negative financial impacts of an

exit cap, changes to exit payment terms and recovery arrangements?


5.5 Equalities impact

Alongside any policy development resulting from this consultation,

legislation requires the Scottish Government to equality impact assess any

new policy and publish the results. We will therefore be carrying out an

Equality Impact Assessment. This is an important part of the policy making

process and will assist in the assessment of how any resulting policy

impacts on people who share 'protected characteristics': age, disability, sex,

gender reassignment, sexual orientation, race, marriage and civil

partnership and religion or belief. It also presents an opportunity to

promote equality.

Specifically in relation to the three needs of the public sector equality duty

in the Equality Act 2010, any new policy will need to have due regard to

the need to:

Eliminating unlawful discrimination

Advancing equality of opportunity

Promoting good relations

33

The Equality Impact Assessment will consider the potential impact of any

new policy with each of the key features of the proposed policy on the

protected characteristics.

Whatever transpires, individual employers will still be required to ensure

that they do not introduce or perpetuate any direct or indirect

discrimination for individuals in their application of the policy outcome.

Question 23

What do you think are the positive and negative equalities impacts of an

exit cap, changes to exit payment terms and recovery arrangements?


5.6 Unintended consequences

With the exception of maintaining the status quo, there may unintended

consequences related to implementing certain options which reduce the

value for money aspects or the ability of public bodies to function

effectively.

Initial comments on possible consequences have included:

Lower exit payments may discourage employees from applying for early

exits – this could affect the ability for public bodies to manage their

staffing levels and cost effectively

There may be a rise in the number of those seeking to exit before any

changes take place - this could impact capacity and the ability of public

bodies to operate effectively

Public bodies may instead engage individuals in ways beyond a normal

employer/employee relationship, such as on a consultancy or contractor

basis to avoid the need for recovery action

There may be other outcomes which have not been foreseen and we would

welcome your thoughts.

Question 24

What unintended consequences do you think might arise from proposals

that go beyond the status quo?

34

6 A case for change

In making final decisions about the issues described in this consultation,

consideration will be given to the impact that changes to severance

arrangements can make on the following key factors:



A desire to ensure that severance payments are not excessive and offer

value for money




Ability of employers to continue to re-shape organisations and deliver

services



Question 25

Do you think these are the appropriate factors to consider when making

the case for change to severance arrangements in the devolved public

sector? Yes / No

From the following list, please select all those you consider to be priority

factors



A desire to ensure that severance payments are not excessive and

offer value for money




Ability of employers to continue to re-shape organisations and

deliver services





Question 26

Are there any other risks you think should be part of Scottish Ministers

decision making on this issue? Yes / No


35

This consultation has sought views on a number of specific policy options

that are deliverable through new and existing powers and has examined

existing measures for exit payments, recovery arrangements and exit

payment terms across the devolved public sector in Scotland.

Question 27

In conclusion, which of the following options best reflects your views of

reform of severance arrangements across the devolved public sector?

Please select appropriate option.

Option 1. Status quo – No reform is required as current

compensation arrangements meet best value and deliver against Fair

Work principles

Option 2. Non-legislative change – Consider reforms to current

devolved compensation arrangements that would improve value for

money and deliver on Fair Work principles but which do not require

use of Regulations

Option 3. Replicating UK arrangements – Agree to make reforms in

line with the reformed Civil Service Compensation Scheme

arrangements and the UK Government’s proposals to implement a

£95,000 exit payment cap and recovery of exit payments for those

who earned more than £80,000 and return to the public sector

Option 4. A hybrid approach – Agree to reform using the powers

conferred on Scottish Ministers and implement a hybrid of legislative

and non-legislative change which could, for example, strengthen

existing severance arrangements and/or introduce some form of

different cap and/or recovery arrangements.


Question 28 / final comments

Any other comments please include them here

36

Annex A

Respondent Information Form Please Note this form must be completed and returned with your response.

Are you responding as an individual or an organisation?

Individual

Organisation

Full name or organisation’s name

Phone number

Address

Postcode

Email

The Scottish Government would like your

permission to publish your consultation

response. Please indicate your publishing

preference:

Publish response with name

Publish response only (without name)

Do not publish response

We will share your response internally with other Scottish Government policy teams who

may be addressing the issues you discuss. They may wish to contact you again in the

future, but we require your permission to do so. Are you content for Scottish Government

to contact you again in relation to this consultation exercise?

Yes

No

Information for organisations:

The option ‘Publish response only (without name)’

is available for individual respondents only. If this

option is selected, the organisation name will still

be published.

If you choose the option ‘Do not publish response’,

your organisation name may still be listed as

having responded to the consultation in, for

example, the analysis report.

37

Annex B

List of references / sources quoted

Bye now, pay later?, Audit Scotland, 2003 (and 1997) – www.audit-

scotland.gov.uk/report/bye-now-pay-later-a-follow-up-review-of-the-

management-of-early-retirement.

Fair Work Framework 2016, Fair Work Convention, March 2016 -

www.fairworkconvention.scot/framework/FairWorkConventionFramewo

rkFull.pdf

Local Government in Scotland: Financial Overview 2015-16, Audit

Scotland, November 2016 - www.audit-scotland.gov.uk/report/local-

government-in-scotland-financial-overview-201516

Managing Early Departures from the Scottish Public Sector, Audit

Scotland, May 2013 - www.audit-

scotland.gov.uk/docs/central/2013/nr_130523_early_departures.pdf

NHSScotland data (2014-15 and 2015-16) – compiled from ‘Staff Report’

sections of individual Board accounts - each Board publishes their

accounts on their own website

Office of National Statistics,

www.ons.gov.uk/economy/nationalaccounts/uksectoraccounts/datasets/

publicsectorclassificationguide

Local government severance data was sourced from a recent survey

undertaken by Fife Council into local government severance schemes across

Scotland

http://www.audit-scotland.gov.uk/report/bye-now-pay-later-a-follow-up-review-of-the-management-of-early-retirement



http://www.fairworkconvention.scot/framework/FairWorkConventionFrameworkFull.pdf

http://www.fairworkconvention.scot/framework/FairWorkConventionFrameworkFull.pdf

http://www.audit-scotland.gov.uk/report/local-government-in-scotland-financial-overview-201516

http://www.audit-scotland.gov.uk/report/local-government-in-scotland-financial-overview-201516

http://www.audit-scotland.gov.uk/docs/central/2013/nr_130523_early_departures.pdf

http://www.audit-scotland.gov.uk/docs/central/2013/nr_130523_early_departures.pdf



w w w . g o v . s c o t

© Crown copyright 2017

This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: [email protected].

Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at www.gov.scot

Any enquiries regarding this publication should be sent to us at The Scottish GovernmentSt Andrew’s HouseEdinburghEH1 3DG

ISBN: 978-1-78652-892-6 (web only)

Published by The Scottish Government, March 2017

Produced for The Scottish Government by APS Group Scotland, 21 Tennant Street, Edinburgh EH6 5NAPPDAS263889 (03/17)

http://nationalarchives.gov.uk/doc/open-government-licence/version/3

http://nationalarchives.gov.uk/doc/open-government-licence/version/3

A Severance Policy for Scotland - consult.gov.scot · The Scottish Government places a high value...

Documents

Transcript of A Severance Policy for Scotland - consult.gov.scot · The Scottish Government places a high value...